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2025 Supreme(P&H) 1473

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
SUMEET GOEL, J.
Inderjeet Suhag And Another – Petitioners
Versus 
State Of Haryana And Others – Respondents 
CRM-M-46800-2025
Decided On : 09-10-2025

Advocates Appeared:
For the Petitioner:Mr. Abhishek Goel, Advocate, Mr. Vishal Singh, Aag Haryana
For the Respondent:Mr. Abhimanu Jangra, Advocate

The court ruled that serious allegations against public servants cannot be quashed based solely on private compromise, stressing public interest and the gravity of office responsibilities.

Headnote:(A) Bharatiya Nagarik Suraksha Sanhita, 2023 - Sections 528, 121(1), 132, 221, 324(6) - Quashing of FIR sought - FIR alleged physical assault and obstruction of official work against public servants - Compromise deed recognized but quashing denied due to nature of allegations - Court emphasized public interest over private settlement, especially with acts against public servants. (Paras 1-15)

(B) High Court's inherent powers of quashing - Distinction between quashing under inherent powers and compounding under Section 320 Cr.P.C. - Compromise insufficient when offences involve serious allegations against public servants. (Paras 10-12)

Facts of the case:
Petitioners sought to quash FIR for assaulting public servants during their duty, based on a compromise that was deemed inadequate for quashing the FIR due to public interest (Para 1, 15).

Findings of Court:
The petition was dismissed based on the premise that the nature of the case involved serious allegations against a public servant which cannot be quashed without due process (Para 15).

Issues: Whether an FIR against public servants can be quashed on the basis of a compromise is the central issue addressed (Paras 7-8).

Ratio Decidendi: The court ruled that quashing based on compromise cannot apply to serious allegations against public servants, emphasizing the need to maintain public order and justice (Para 11-12).

Result: Petition dismissed, confirming the FIR remains valid.

Table of Content
1. factual background of the case (Para 1 , 2)
2. arguments of petitioners and respondents regarding fir (Para 3 , 4 , 5)
3. consideration of compromise regarding public interest (Para 6 , 7)
4. analysis of legal principles regarding quashing of fir (Para 8 , 9)
5. conditions for quashing fir involving public servants (Para 10 , 11 , 12)
6. final decision on petition for quashing fir (Para 14 , 15)
7. mandate for compliance and consequential actions (Para 16)

JUDGMENT :

SUMEET GOEL, J.

1. The petition in hand has been preferred by the accused – petitioners under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, for quashing of FIR No.234 dated 22.08.2024 (hereinafter to be referred as the impugned FIR) registered under Sections 121 (1), 132, 221, 324(6) of BNS at Police Station Beri, Jhajjar, Haryana, as also the proceedings subsequent thereto, on the basis of a compromise deed dated 07.08.2025 (Annexures P-2, P-4 and P-6) appended with the present petition.

2. The gravamen of the impugned FIR is that on 21.08.2024, employees namely Rakesh (Lineman), Sunil (Assistant Lineman) and Mohit (Assistant Lineman) (respondent Nos.2 to 4 herein) were on night duty at the complaint centre, Beri, when around 11:40 P.M. they returned from a complaint` visit to Jat Dharamshala, Beri. When they reached the complaint centre, which is located in the Dharamshala, some people present there stopped them from entering by saying that they had booked the Dharamshala for their own use. The employees explained that it was the official complaint center and they were on night duty. During this argument, the villagers informed the Sarpanch of Bishan village namely Indrajit Suhag who alongwith his sons came to the spot. Without any discussion, they started abusing, threatening and physically assaulting the employees. They also threatened to kill them and get them fired from their jobs. When the employees tried to contact the Junior Engineer (JE) namely Anil on the government phone, Sarpanch namely Indrajit Suhag threw the phone away by saying that he did not know any JE. This incident created fear amongst the employees making it unsafe for them to perform night duty at the complaint Centre. In view of this, a request was made to register an FIR against Sarpanch Indrajit Suhag and his sons for obstructing government work; issuing death threats and damaging a government phone. Furthermore, employee namely Rakesh and Mohit were injured during the course of the aforesaid occurrence. After investigation, it was found that offences under Sections 132 , 221, 324, 6 of BNS and other relevant law had been committed. Accordingly, the instant case was registered. On 24.08.2024, based on the evidence, accused Inderjeet Suhag and Akshay Suhag (petitioners herein) were arrested and their statements were recorded. Based on these set of allegations, the impugned FIR was got registered.

3. Learned counsel for the petitioners has argued that the petitioners have been falsely implicated into the impugned FIR, whereinafter the trial Court has already taken cognizance of the case, issued process against the petitioners and fixed 17.09.2025 for framing of charges. According to learned counsel, the petitioners are on regular bail and have been regularly appearing before the trial Court. Learned counsel for the petitioners has further submitted that a compromise was entered into between the petitioners and the FIR-complainant on 07.08.2025 (colly), relevant whereof reads as under:-

“1. That the case FIR No. 234 dated 22.08.2024 under section 121 (1),132, 221, 324(6) of BNS has been registered by the Deponent against the second parties/accused (Mr. Inderjeet Suhag 5/o Late Sh. Karan Singh and Mr. Akshay Suhag 5/o Sh. Inderjeet Suhag) at P.S. Beri, Jhajjar, Haryana.

2. That the said FIR was registered as the Deponent had mistakenly Identified the second parties/accused (Mr. Inderjeet Suhag S/o Late Sh. Karan Singh and Mr. Akshay Suhag S/o Sh. Inderjeet Suhag) and

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